Hunter avoids paying the fine and the interest penalties...............
Ah, let me change that paragraph:
Hunter would owe nothing more or less, he’d just be out the $2MM retainer (same as his tax bill). Gift donees don’t owe gift taxes unless they agree to be the owing party, the IRS default is the donor owes it.
The lawyer, as the one giving the gift, would owe taxes on the $2MM income from the retainer, as well as the gift tax on $1,985,000 of the gift, since he certainly used up his $15M annual exclusion per gift recipient. Of course, that taxable amount could be lowered by $15M per person if the lawyer “has his wife pay” for some of the gift (over and above the $15M exclusion), as well as have all his partners or clerks or whatnot make a gift as well. (133 other people is enough to zero out any owed gift tax!) Of course, if he gifts each of them $15M for the purpose of them then gifting that money to Hunter, for the sole purpose of paying less gift tax, I doubt the IRS would like that very much...
So still, Hunter has the same bill wither way, the lawyer loses money if he agrees to such a convoluted scheme!